CORRUPTION and rule-breaking have plagued the adoption of Cambodian children to foreign countries in recent years, according to NGOs who warn the system is open to abuse.

Officials, including within the Ministry of Social Welfare and the Council of Ministers, are accused by some NGOs of taking bribes to approve adoptions.

Some children adopted abroad are not orphans, sources say, and Cambodian "middlemen" are feared to have bought children from poor families for the international adoption process.

Foreign adoption agents have also been active in Cambodia, and been permitted to personally take children out of the country, contrary to the law.

Since 1991, it has been legally banned for children to be released into the custody of intermediaries, rather than directly to adoptive parents who come to Cambodia to pick up the children.

The government does not know the whereabouts of many youngsters adopted to foreigners, "and doesn't have any guarantee that these children are even alive," according to one NGO source.

Officially, adoptions require the approval of several government departments, the Council of Ministers and the Prime Ministers.

The reality, according to NGOs, is that graft is common and adoptions have been approved by high-ranking officials without going through the normal screening.

International adoptions have been suspended by Cambodia several times, but always continued. Their numbers have been small but growing - official figures are 49 last year and 20 so far this year. France and the United States have been the biggest receivers of Khmer children.

The Secretary of State for Social Affairs, Suy Sem, was recently given a list of nine named foreign adopters who said they had paid money to Cambodian government officials. In all, 14 officials were named in the list, which was included in a letter to Suy Sem from an NGO worker.

The letter came as pressure mounted on the government to take action from some NGOs.

Three weeks ago, the Ministry of Social Affairs closed the gates to Phnom Penh's Nutrition Center, the main state-run orphanage for sick or malnourished children, which is the subject of many of the allegations.

Guards were stationed at the center, preventing foreigners and even some ministry staff from entering. One foreigner, sent away, exclaimed: "But I've already paid $5,000 to [a senior ministry official]," according to a witness.

The ministry is now permitting access to the center - which had earlier descended into "anarchy", by its own admission - for people who have been approved to adopt.

Earlier, in January, after NGOs warned the situation was getting out of control, the ministry froze all inter-country adoptions.

The freeze soon thawed. Subsequent adoptions included that of a Cambodian baby who, according to one NGO worker who monitors adoptions, had been bought by a middleman from a poor, rural family for several hundred dollars. The child went to a Belgian family.

"I'm sorry, but this is trafficking," said the NGO representative, who, like most contacted for this story, requested anonymity.

"There are people making money from this. Why do foreigners come here? They know...they can come here, pay money and have a child."

Last year, the going rate was $1500 for an adoption application to be approved within 15 days, according to the chief of another NGO.

But he disputes that adoptions have become big business. Corruption is small-scale, he says, though "nothing is done without payment."

He, and other NGO workers, acknowledge that most prospective adopters have good intentions. But they warn that short-cuts in the adoption process - and the influence of money - can make a dangerous mix, opening the system to abuses.

Most adoptions have been from Phnom Penh's Nutrition Center, though others have been made from the privately-run Cambodia House (formerly Canada House) and provincial orphanages.

Last year saw a rapid increase in adoptions. Of the 87 international adoptions made between 1993-95, according to officials, 49 were made from the Nutrition Center last year.

Charles Fejto, director of the French organization ASPECA, which funds the Nutrition Center, confirmed there were cases of children being put in the orphanage for several days before being adopted.

He said this was apparently done to satisfy adoption rules, but he was unsure of where the children originally came from. Asked if they had been bought from poor families, he said: "I don't know. I don't say it doesn't happen, but I don't know."

Fejto said he was aware of foreigners adopting children from the orphanage without going through the Ministry of Social Affairs but who had the necessary paperwork from "very important" people.

The adoptions "go through very quickly," he said. "I cannot do anything. I am not a lawyer, I'm outside of politics...[but] I think it's strange to have a law that says something...and some children can go abroad without these procedures."

Center manager Yuon Sovanna said that, of the 49 international adoptions made from the orphanage last year, most went to France (29 children) and the US (10), and the rest to Australia, Canada, Germany, Belgium or Switzerland.

Sovanna said most adopters had not come to Cambodia before choosing a child. "They decide to adopt children only after they see photographs of them...when the adoption is approved, they come to pick up their children."

Fejto confirms at least one such recent case, of a Canadian family who wanted to adopt a Cambodian girl they saw in a "catalogue".

Several NGO workers are critical of the staff and conditions at the Nutrition Center, alleging some staff regularly seek payment from adopters, and that mismanagement and poor standards are common there.

"You cannot separate adoption and the Nutrition Center," said one. "The adoption problems reflect mismanagement of the Nutrition Center...and the type of shopping for children that goes on there."

Another NGO source said recent events at the center include a Belgian man being given approval in December to take a girl overseas for three months for health treatment; yet to return, there was uncertainty about her whereabouts.

Also, at one stage, two soldiers were taking two children - a boy and a girl - out of the center two nights a week. The soldiers said they would adopt the children but, when a foreign aid worker challenged their nighttime behavior, they disappeared. The children had refused to say what happened to them while out of the center.

Several sources say the care and medical treatment of children at the orphanage has at times been appalling. For instance, when the majority of children there got scabies, a nurse shaved their heads with the same razor, cutting some of them - potentially spreading the HIV-Aids virus, which a number of them have tested positive for.

The food at the orphanage is said by one NGO worker to be poor, and many children are heavily sedated without reason. Over the last Khmer New Year, children aged 1-5 were locked in the building without nurses.

Several NGOs questioned why ASPECA - whose director, Charles Fejto, lives in France and spends three out of every nine weeks in Cambodia - has not done more.

Fejto replied that until recently his designated manager, Sovanna, held little real power.

ASPECA recently began supplementing the wages of the orphanage nurses, he said, and would "say good-bye to" any who did not work well.

ASPECA had increased its funding of the center from about $1500 a month a year ago to $4000 a month now, and "we will see the difference."

Suy Sem, the Secretary of State for Social Affairs, was too busy to talk to the Post, as was his deputy, Hong Themm. But Touch Samon, director of the ministry's Social Affairs Department, said the Nutrition Center had been in a state of anarchy.

"People went there to select children before submitting [adoption] applications with the department," he said, but denied that children were removed without official clearance.

Security had been tightened at the center, and other precautions were being taken to address "inefficiencies" in the adoption process.

The ministry was setting up a special adoption unit, which would draft a new adoption law, he said.

Samon denied corruption was common in adoptions, or that applications had been approved without thorough examination.

He confirmed the ministry did not know the whereabouts of some children adopted overseas, but it had no evidence that any had gone to improper people.

Samon said the ministry's January suspension of international adoptions followed concern about "improper acts" by Cambodian middlemen.

"We also received information from abroad regarding adopted children who were being sold abroad...," but scrutiny of adoption dossiers had not identified any such cases involving Cambodian children.

The ministry was no longer allowing intermediaries, foreign or Cambodian, to file applications or receive adoptive children, he said.

Asked why such a ban - required by law since 1991 - had not been enforced earlier, he said: "We acknowledge loopholes in the practice of the law since 1991."

Samon confirmed that the ministry's recent action had also been, in part, because of concern about two American adoption agents, though it had no evidence they had acted improperly.

Charles Fejto told the Post that the two had added to the "very bad" situation at the Nutrition Center.

"What I saw myself was two cases of American citizens coming here and taking - I don't say buying - many children together," he said, adding that it was very dangerous for groups of children to be taken away by adoption agents.

He would not identify the two, who he said had "all the approvals from the two Prime Ministers".

However, sources said the two were Elsie Webber - a biographer of Second Prime Minister Hun Sen and a former refugee aid worker - and Lauryn Galindo, from a Hawaii adoption agency.

Webber, from Texas, could not be contacted for comment. Adoption officials, and advisers to Hun Sen, said they did not know how to contact her.

Galindo, contacted in Hawaii, strongly denied any wrong-doing in an eight-page reply to Post questions.

Acknowledging that her name had appeared in a Cambodian government document alleging "illicit activities", Galindo released a copy of a February letter to Secretary of State Suy Sem expressing her "shock and dismay" at this.

Galindo, from the Adopt International agency, said she was subjected to yearly registration, and criminal record checks, in the US as a licensed adoption agent.

Over the past nine years, she had been involved with hundreds of adoptions from 12 countries, placing children in 26 US states. All her adoptive families had to be screened by US authorities.

In Cambodia, she adopted out four children last November, and nine in April this year. The only "unpleasant person" she had encountered in Cambodia was Charles Fejto, who made comments about her work which were "libelous in nature."

In response to questions, Galindo said she had never paid money directly to Cambodia officials, but had made donations to the Nutrition Center and paid "a reasonable gratuity" to "several assistants" in Cambodia.

"Having been the victim of slander already, please excuse me for being unwilling to be more specific about monies paid and to whom...I have nothing to hide, I just cannot see any benefit of such disclosure."

Galindo said she took her responsibilities very seriously, and aimed at providing loving homes to children.

"I am confused that NGOs are critical of my work...why didn't anyone attempt to contact me to inquire about my activities or even to offer helpful advice? I feel I am a reasonable, approachable person, and would welcome alliance with others who wish to better the plight of children in the world."